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CFTC Issues New Guidance Prioritizing Compliance Programs in Enforcement Decisions

On September 10, 2020, the Commodity Futures Trading Commission (the CFTC) issued a new guidance memorandum outlining factors that the Division of Enforcement (the division) will consider when evaluating compliance programs...more

Resolutions Highlight Aggressive Sanctions Enforcement, Need For Senior Level Commitment to Compliance

On July 16, 2020, Essentra FZE Co. Ltd., a manufacturer of components for cigarettes located in the United Arab Emirates, agreed to a settlement with the U.S. Department of the Treasury’s Office of Foreign Assets Control...more

New DOJ Policy Seeks to Avoid “Piling On” Corporate Penalties

On May 9, 2018, the U.S. Department of Justice (DOJ) issued a new, non-binding policy that aims to curtail the “piling on” of corporate penalties by different government authorities to punish the same wrongdoing. The policy...more

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